The
full comments, with attachment, are available in PDF format.

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the matter of
Auction of Broadband Radio Service Licenses (AU Docket 09-56)
Comment on Competitive Bidding Procedures for Auction 96

COMMENTS OF
THE PUBLIC INTEREST SPECTRUM COALITION

On behalf of the Public Interest Spectrum Coalition,^[1] Public Knowledge submits these comments
in response to the Public Notice in the above docketed proceeding. We
commend the Wireless Telecommunications Bureau (Bureau) for proposing to
adopt anonymous bidding for Auction 86.

Please see the
full filing in PDF format.

On behalf of the Public Interest Spectrum Coalition (PISC) and the
Champaign Urbana Wireless Network (“Petitioners”), the New
America Foundation and Public Knowledge respectfully submit the following
Opposition to Petitions for Reconsideration of the
Commission’s TV band white space rules.

These comments are also available in
PDF format.

The NTIA has been presented with an extraordinary opportunity to improve
access to, encourage competition among and increase the speed,
affordability and openness of broadband services. Recognizing the
transformative effect that broadband services can have in communities and
the potential for such services to promote economic activity, civic
discourse and innovation, Congress crafted a set of broadband initiatives
that would promote the use of broadband while ensuring, though a set of
public interest conditions, that taxpayers would receive a long-term
return on their investment. PISC urges the NTIA to ensure that these
conditions are met and enforced and to utilize the funds allocated by the
Stimulus Act to make a meaningful impact in the lives of Americans in
unserved and underserved areas. As such, PISC proposes the following:

This filing is also available in PDF Format.

The Ad Hoc Public Interest Spectrum Coalition (PISC) respectfully submits these comments in support of the Petition for Rulemaking filed by the Rural Cellular Association (RCA). The Commission should consider issuing a Notice of Proposed Rulemaking to limit the widespread use and anticompetitive effects of exclusivity arrangements between commercial wireless carriers and handset manufacturers, arrangements which limit consumer choice over devices and providers. The market for wireless services in 2009 is concentrated and will continue to grow more concentrated as large carriers absorb competitors and acquire disproportionate shares of newly available spectrum. Worse, the market does not promote competition over quality and cost of wireless service--competition that benefits consumers directly--due in part to the widespread use of exclusivity arrangements that prevent would-be subscribers to rural and competitive wireless services from acquiring the newest and most popular wireless devices. Prohibiting exclusivity arrangements encourages innovation and promotes beneficial competition, reducing prices for consumers and improving quality of service, by taking carrier control out of the device market.

Also available in PDF Format.

Public Knowledge urges the Commission to clarify that text messaging, including the offering of short codes to the public, is a Title II common carrier service subject to all of the protections of Title II, including §202’s nondiscrimination protections and §255’s accessibility requirements.

This petition is also available in PDF format.

Before the

FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, DC 20554

In the Matter of

Sprint Nextel Corporation and Clearwire Corporation Application for Consent to Transfer Control of Licenses and Authorizations

WT Docket No. 08-94

To: The Commission

PETITION FOR RECONSIDERATION OF THE PUBLIC INTEREST SPECTRUM COALITION

Media Access Project, on behalf of the Public Interest Spectrum Coalition (PISC),^[1] hereby submits this Petition for Reconsideration in the above captioned proceeding. PISC seeks reconsideration of the Commission’s decision to include Broadband Radio Service (BRS) spectrum in its “spectrum screen.” In addition, PISC seeks reconsideration of the Commission’s refusal to impose a modest condition of contractual review to ensure that New Clearwire will provide the open networks promised in its public interest statement. Alternatively, PISC requests that the Commission clarify the manner in which it intends to hold New Clearwire accountable to its open network commitments by application of the Internet Policy Statement.

Letter in PDF format.

November 13, 2008

Chairman Kevin J. Martin
Commissioner Michael J. Copps
Commissioner Jonathan S. Adelstein
Commissioner Deborah Taylor Tate
Commissioner Robert M. McDowell
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

RE: Revisions to Rules Authorizing the Operation of Low Power Auxiliary Stations in the 698-806 MHz Band, WT Docket No. 08-166; Public Interest Spectrum Coalition, Petition for Rulemaking Regarding Low Power Auxiliary Stations, Including Wireless Microphones, and the Digital Television Transition, WT Docket No. 08-167

Dear Chairman Martin and Commissioners:

The undersigned wireless providers, associations, manufacturers, public safety entities and public interest groups respectfully urge the Commission to take swift action to ensure that the use of low power auxiliary stations (e.g., wireless microphone systems) in the 700 MHz band does not threaten the future use of important spectrum that is being made available with the DTV transition.

Original Filing in PDF Format

The undersigned public interest organizations are writing to in support of Verizon Communications' recent filing expressing concern with the cable industry's plan to use the successor to CableCARD to limit competition and reduce choice in the consumer electronics marketplace. We also reiterate our objection to a standard that stifles third party innovation in the consumer video market, and our support for a unified, open standard. A restrictive standard would be contrary to both the spirit and letter of Section 629 of the Telecommunications Act of 1996.

The full ex parte notice is available in PDF format.

On October 29, 2008, Harold Feld of Media Access Project, Alex Curtis of Public Knowledge, Michael Calabrese and Sascha Meinrath of the New America Foundation (collectively “PISC”), and Mark Lloyd of the Leadership Council on Civil Rights, met with Commissioner Jonathan Adelstein, his Wireless Advisor Renee Crittendon, and his Media Advisor Rudy Brioche, with regard to the above captioned proceeding.

The full ex parte notice is available in PDF format.

On October 28, 2008, Harold Feld of Media Access Project spoke with Bruce Gottlieb, Wireless Advisor to Commissioner Copps, with regard to the above captioned proceeding.